Federal officials confirmed last week that separate physical inventories are not required for compliance with 340B group purchasing organization (GPO) prohibition guidance, which clarifies the policy that forbids certain entities in the 340B program from obtaining covered outpatient drugs through a GPO or other group purchasing arrangement. In preparation for the Aug. 7 deadline for compliance with the Office of Pharmacy Affairs (OPA) GPO prohibition guidance, OPA provided a frequently asked question (FAQ) with information on the type of inventory and accumulation/replenishment process that the Health Resources and Services Administration will “consider compliant for a covered entity that (1) is subject to the GPO prohibition; and (2) maintains a physical inventory in a mixed use setting.” The FAQ explicitly confirms that it is permissible “to dispense or administer a drug from the covered entity’s physical inventory – regardless of the drug’s contract purchase origin – and subsequently accumulate that drug in the applicable accumulator (i.e., 340B, GPO, or non-GPO accounts)…” For the full text on this topic, see the last FAQ under “GPO Prohibition” on OPA’s website. In addition, for your reference, the Healthcare Supply Chain Association (which represents GPOs), sent to OPA and shared with America’s Essential Hospitals their own analysis of the impact of the FAQ prepared by their counsel.
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